SEC Comment Letter for MARA Holdings, (MARA) — Jun 10, 2014
MARA Holdings, Inc.
Date: June 10, 2014 · CIK: 0001507605 · Accession: 0000000000-14-029421
AI Filing Summary & Sentiment
Referenced dates: May 30, 2014, May 9, 2014
Letter
June 10, 2014 Via E -mail Doug Croxall Chief Executive Officer Marathon Patent Group, Inc. 2331 Mill Road, Suite 100 Alexandria, VA 22314
Re: Marathon Patent Group, Inc. Amendment No. 1 to Form 10-K for the Fiscal Year Ended December 31, 2013 Filed May 30, 2014 Form 8 -K Filed January 22, 2014 File No. 000 -54652
Dear Mr. Croxall :
We have the following comments after reviewing your letter dated May 30, 2014 and the above -referenced filing . Unless otherwise noted, where we reference prior comments we are referring to our letter dated May 9, 2014.
Amendment No. 1 to Form 10 -K for the Fiscal Year Ended December 31, 2013
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 25
1. We note your response to prior comment 5. Please ensure in future filings that you discuss each material agreement individually, including the amount of revenue attributable to each agreement . Describe any differing licensing terms in the agreements such as provisions related to sub -licensing .
Form 8 -K filed January 22, 2014
Exhibit 99.1
2. Please c onfirm that you will include the underlying assumptions you discuss in your letter and a statement regarding the uncertainties and limitations of your projections when and i f you update this information.
Doug Croxall Marathon Patent Group, Inc. June 10, 2014 Page 2
Please contact Mitchell Austin, Attorney -Advisor, at (202) 551 -3574 or me at (202) 551 - 3453 with any questions.
Sincerely,
/s/ Jan Woo
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June 10, 2014
Via E -mail
Doug Croxall
Chief Executive Officer
Marathon Patent Group, Inc.
2331 Mill Road, Suite 100
Alexandria, VA 22314
Re: Marathon Patent Group, Inc.
Amendment No. 1 to Form 10-K for the Fiscal Year Ended
December 31, 2013
Filed May 30, 2014
Form 8 -K
Filed January 22, 2014
File No. 000 -54652
Dear Mr. Croxall :
We have the following comments after reviewing your letter dated May 30, 2014 and the
above -referenced filing . Unless otherwise noted, where we reference prior comments we are
referring to our letter dated May 9, 2014.
Amendment No. 1 to Form 10 -K for the Fiscal Year Ended December 31, 2013
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 25
1. We note your response to prior comment 5. Please ensure in future filings that you
discuss each material agreement individually, including the amount of revenue
attributable to each agreement . Describe any differing licensing terms in the agreements
such as provisions related to sub -licensing .
Form 8 -K filed January 22, 2014
Exhibit 99.1
2. Please c onfirm that you will include the underlying assumptions you discuss in your
letter and a statement regarding the uncertainties and limitations of your projections when
and i f you update this information.
Doug Croxall
Marathon Patent Group, Inc.
June 10, 2014
Page 2
Please contact Mitchell Austin, Attorney -Advisor, at (202) 551 -3574 or me at (202) 551 -
3453 with any questions.
Sincerely,
/s/ Jan Woo
Jan Woo
Attorney -Advisor
cc: Via E-Mail
Edward Schauder , Esq.
Sichenzia Ross Friedman Ference LLP